Back
SANJAY KISHAN KAUL, ABHAY S. OKA
Sudesh Chhikara – Appellant
Versus
Ramti Devi – Respondent
JUDGMENT :
Abhay S. Oka, J.
FACTUAL DETAILS
1. This appeal arises out of a petition filed by respondent no.1 under Section 23 of the Maintenance and Welfare of Parents and Senior Citizens Act, 2007 (for short, ‘the 2007 Act’).
2. Respondent no.1 acquired a land bearing Khewat no.87, Khatoni no.124, Khasra no.315 measuring 1 bigha 18 biswa. She also acquired a land bearing Khewat No.247, Khasra No.269 (4 bighas 0 biswa) totally measuring 5 bighas and 3 biswa in Village Basai, Tehsil and District Gurugram, Haryana. She claimed that the acquisition was by way of inheritance from her father. The family tree of the parties is as under :
| Ramti Devi W/o. Late Sukh Lal (Respondent no.1) | ||
| Smt. Suresh (dead) (daughter) | Smt. Sudesh (daughter) Appellant | Sunder (son) |
| Jasdeep (Respondent no.2) | Manish | |
3. Respondent no.1 executed a release deed in respect of a part of the subject property in favour of her daughters (the appellant and second respondent’s mother). The said release deed (no.18151) was executed on 14th November 2008 and was duly registered. As per the sa
[No cases identified as bad law. None of the entries contain keywords or phrases indicating overruling, reversal, abrogation, or treatment as bad law (e.g., no mentions of "overruled", "reversed", "abrogated", "bad law", or equivalent negative treatments). All references treat the cited cases positively or neutrally.]
[All cases in the list fall into this category, as they uniformly cite *Sudesh Chhikara v. Ramti Devi* (and variants like *Sudesh Chhikara vs. Ramti Devi and Anr.* or *Ramti Devi and another*) as binding or persuasive authority from the Supreme Court ("apex court"). This case is referenced positively across multiple entries with language indicating reliance, fortification of views, or direct application of its principles. Brief explanations for each:]
Pramod. V. , S/o. Devu VS Vimala. V, D/o. Chirutha - 2024 0 Supreme(Ker) 828: "the counsel for the petitioner relied on the judgment of the apex court in Sudesh Chhikara vs. ... Ramti Devi [2022 (7) KHC 637], whereby the apex court held that the Tribunal can invoke the power under" – Explicit reliance on the case as precedent.
AYYAPPAN vs MUHAMMED SHEFEEQUE - 2024 Supreme(Online)(KER) 35269: "precedent - The case established that property transfers to senior citizens must include conditions for care to be set aside under Section 23. InSudesh Chhikara v. Ramti Devi" – Labels it explicitly as "precedent" and summarizes its holding.
Urmila Dixit VS Sunil Sharan Dixit - 2025 1 Supreme 130: "In Sudesh Chhikara v. ... Ramti Devi and Anr., 2022 SCCOnline SC 1684, this Court refused to grant the benefit of Section 23... Furthermore, in Sudesh (supra) for attracting the application of Section 23(1), the following essentials were expounded" – Cites it as authority ("this Court", "supra") and expounds its essentials.
Mendu Narsimha Reddy vs State of Telangana - 2025 Supreme(Online)(TEL) 4331: "gift - Established that conditions for transfer must be proven. Ramti Devi and another" – Describes it as establishing a legal principle.
JAYASHREE W/O. RAMESH KERALLI vs THE DEPUTY COMMISSIONER, Dharwad D. C. OFFICE, KOPPAL - 2025 Supreme(Online)(KAR) 5878: "Our view is fortified by the dictum of the Hon'ble Supreme Court in the case of Sudesh Chhikara -vs- Ramti Devi... The Apex Court in the case of SUDESH CHHIKARA v." – Explicitly states the view is "fortified" by the case.
Shriya Uppati vs State of Telangana - 2025 Supreme(Online)(TEL) 3812: "Ramti Devi and another" – Direct citation in context of reliance (grouped with similar supra references).
P.Rohit Saurya vs The State of Telangana - 2025 Supreme(Online)(TEL) 4796: "Ramti Devi and another (supra)... Ramti Devi and another (supra), wherein it was observed as under:'13.'" – Cites as "supra" and quotes paragraph 13 approvingly.
P. Rohit Saurya vs State of Telangana - 2025 Supreme(Online)(TEL) 4796: "conditions for transfer - The Supreme Court clarified... Ramti Devi and another (supra)... Ramti Devi and another (supra), wherein it was observed as under:'13.'" – Cites as "supra" and quotes approvingly.
Ashokan S/o. Sreenivasan vs Appellate Tribunal, Under The Maintenance And Welfare Of Parents And Senior Citizen Act, Ernakulam - 2025 0 Supreme(Ker) 1526: "Ramti Devi" – Citation in reliance context (consistent with surrounding entries).
Karuppan vs District Magistrate-cum-District Collector, Appellate Tribunal under the Maintenance of Parents & Senior Citizens Act - 2025 0 Supreme(Mad) 4530: "Ramti Devi [Sudesh Chhikara v. ... 'In Sudesh Chhikara Vs. ... In the case of Sudesh Chhikara Vs." – Repeated invocation as controlling authority.
Mandadi Sulochana vs Appellate Tribunal for Maintenance and Welfare of Parents - 2025 Supreme(Online)(Tel) 16117: "Ramti Devi and another, (2022) 17 SCR 876... In Sudesh Chhikara (supra), in paragraph No.13, the Apex Court held as follows:-13. ... Thus, as per the principle laid down by the Apex Court in Sudesh Chhikara" – Cites "supra", quotes para 13, and applies its "principle".
Kurakula Gajendra Mohan vs Kurakula Shanta - 2025 0 Supreme(Telangana) 983: "Ramti Devi, [2022 (17) SCR 876]... In Sudesh Chhikara (supra), in paragraph No.13... relying on the principle laid down in Sudesh Chhikara (supra)" – Cites "supra" and relies on its "principle".
V. Nanda Kumar S/o B.N. Venkateshaiah vs Assistant Commissioner Bengaluru North Sub-Division - 2025 0 Supreme(Kar) 2847: "Ramti Devi and Another" – Citation in reliance context.
M.Vasanthi vs M.M.Nagarajah Pillai - 2025 Supreme(Online)(Mad) 65257: "void transfer - The Supreme Court articulated the essentials... Ramti Devi & another. ... since twin essentials which had been set out in Sudesh Chhikara" – Applies its "essentials" to quash a deed.
M.Vasanthi vs M.M.Nagarajah Pillai - 2025 Supreme(Online)(Mad) 65257: "void transfer - The Supreme Court articulated the essentials... Ramti Devi & another. ... since twin essentials which had been set out in Sudesh Chhikara" – Identical to above, applies essentials.
K. Srinivasa Reddy vs State of Telangana, rep. by its Principal Secretary, Revenue Department - 2025 0 Supreme(Telangana) 2204: "Further, in Sudesh Chhikara vs. ... Ramti Devi and another (supra). ... He placed reliance on the decision of the Hon’ble Supreme Court in Sudesh Chhikara vs." – "Placed reliance" and cites as "supra".
SMT. T.S. SHARADHA vs THE REVENUE DIVISIONAL OFFICER - 2025 Supreme(Online)(Ker) 57487: "rd respondent relied on the judgment of the Apex Court inSudesh Chhikara" – Notes reliance by party on the judgment.
K.Poongothai vs The District Collector, Office of the District Collector, Sivagangai District - 2026 Supreme(Online)(Mad) 17272: "transfer conditions - Outlines necessary conditions... Ramti Devi & another... The judgment of the Hon'ble Supreme Court reported in(2024) 14 SCC 225 (Sudesh Chhikara Vs." – Cites and applies its outline of conditions.
SETHUMADHAVAN.T.N vs MAINTENANCE TRIBUNAL, THRISSUR - 2026 Supreme(Online)(Ker) 19182: "The Apex Court in Sudesh Chhikara v. Ramti Devi" – Direct citation of holding.
S.Muthulakshmi vs The Revenue Divisional Officer, Pattukottai, Thanjavur District - 2026 Supreme(Online)(Mad) 33800: "essentials - Outlines essentials for Section 23(1)... 2024 (14) SCC 225 : 2022 SCC Online SC 1684 in Sudesh Chhikara Vs. Ramti Devi & another. ... the two conditions mentioned in Sudesh (supra)" – Cites as "supra" and interprets its conditions.
[No entries in other treatment categories (e.g., distinguished, criticized, questioned), as no such language appears.]
[None. All entries clearly reference the same core case (*Sudesh Chhikara v. Ramti Devi*) positively as precedent, with consistent citations, quotes, and applications. Minor variations in party names (e.g., "Ramti Devi", "Ramthi Devi") or citations (e.g., SCC, SCR, KHC) do not create ambiguity in treatment.]
An indispensable Tool for Legal Professionals, Endorsed by Various High Court and Judicial Officers
Please visit our Training & Support
Center or Contact Us for assistance
Scan Me!
India’s Legal research and Law Firm App, Download now!
For Daily Legal Updates, Join us on :
Back to top
